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Jamal Watson v. Tennessee Board Of Regents

Tenn. Ct. App.January 12, 2018No. E2017-00014-COA-R3-CV
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Case Details

Judge(s)
Judge Charles D. Susano, Jr.
Status — whether other courts must follow this ruling
Published
Procedural Posture — the stage the case had reached
appeal

Related Laws

No specific laws identified for this ruling.

Claim Types

DiscriminationBreach of Contract

Outcome

The Court of Appeals reversed the trial court's dismissal, holding that filing a breach of contract claim with the Tennessee Claims Commission did not waive Watson's THRA race discrimination claim against PSCC and TBR because those entities are not 'state officers or employees' under the statute.

Excerpt

This case involves the dismissal of a Tennessee Human Rights Act (THRA) action filed by Jamal Watson against the Tennessee Board of Regents (TBR) and Pellissippi State Community College (PSCC) (collectively the defendants). PSCC offered Watson a fulltime, tenure-track position, but subsequently rescinded the offer. Watson filed a THRA case in the Circuit Court for Knox County (the trial court) against the defendants alleging race discrimination. He later filed a notice of claim for breach of contract in the Tennessee Claims Commission against the same entities. The defendants filed a motion to dismiss in the trial court alleging that the court lacked subject matter jurisdiction. The defendants asserted that Watson waived his cause of action against "any state officer or employee," pursuant to Tenn. Code Ann. § 9-8-307(b), by filing a claim against the state in the Tennessee Claims Commission. The trial court granted the motion to dismiss. Watson appeals. We reverse.

What This Ruling Means

**What Happened:** Jamal Watson was offered a full-time, tenure-track teaching position at Pellissippi State Community College, which is part of the Tennessee Board of Regents. However, the college later took back this job offer. Watson believed the college rescinded his offer because of his race, so he filed a lawsuit claiming racial discrimination under Tennessee's Human Rights Act. He also claimed the college broke their contract with him by withdrawing the job offer. **What the Court Decided:** The court dismissed Watson's case, meaning his lawsuit was thrown out. The court did not award him any money or other compensation. While the excerpt doesn't provide the full reasoning, the dismissal suggests the court found either that Watson couldn't prove his claims or that there were procedural problems with his case. **Why This Matters for Workers:** This case shows how difficult it can be for workers to successfully challenge rescinded job offers, even when they believe discrimination was involved. Workers should know that simply having a job offer withdrawn doesn't automatically mean they have a strong legal case. To win discrimination lawsuits, employees typically need solid evidence that their race (or other protected characteristics) was the actual reason for the employer's decision, not just their suspicion that discrimination occurred.

This summary was generated to explain the ruling in plain English and is not legal advice.

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